The Association for Clinical Oncology (ASCO) responded to the Centers for Medicare & Medicaid Services (CMS) Request for Information (RFI) on electronic prescribing of controlled substances (EPCS). ASCO supports safe and unburdened access to opioids for people with cancer and asserts that EPCS provides benefits that can improve the quality of cancer care.
For Medicare beneficiaries, EPCS can reduce logistical burdens and provide patients with timely access to prescriptions. For providers, e-prescribing can help deter and detect prescription fraud and irregularities, allow for timely and accurate data collection, and potentially reduce provider burden.
ASCO urges CMS to consider the unique needs of patients with cancer who require controlled substances as an important component of their care. Specifically, ASCO’s comment letter states:
- Patient access to appropriate pain medication is critical and CMS should not impose any restrictions, penalties, or limitations that may interfere with patient access. CMS should recognize that some Medicare beneficiaries may prefer a traditional prescription. This process should not be interrupted, as the required reporting associated with prescribing controlled substances can still occur in these instances. ASCO also supports e-prescribing waivers for practices with in-office dispensing.
- Costs associated with updating systems may also be prohibitive for some small practices that may not have electronic health records. Penalties should not be imposed while providers are working to implement the technology that will allow them to comply with e-prescribing requirements. Many providers—particularly in small practices—are still in the process of electronic health record (EHR) implementation or upgrades and need time to complete this transition.
Read the full comment letter.
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